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The proposed regulation allows to much interpretation. Many of the proposed criteria are vague, and allow the ATF to choose at a whim what is and is not subject to the new regulation. It is up the individual doing the assessment if the rear surface is "useful for shouldering". The regulation is also designed to specifically assess points regardless of the design being evaluated, assigning points for "Rifle type back-up/flip-up sights/or no sights" So regardless of what type of sights you have on your pistol you are getting additional points.
That leads to the crux of the regulation. This regulation change is designed entirely to target AR pistols with braces that have been legally purchased by non criminals in incredibly large numbers. This regulation seeks to create criminals our of those who have complied with the law.
This regulation intends to make these braced rifles subject to the NFA. However, they are already present in very large numbers within our country. They pose no additional threat to the public, and are not in anyway more lethal. There isn't an outcry against the millions of these weapons in the possession of our citizenry. This regulation therefore won't stop any crime, it will only create crime de jure without crime de facto.
In much the same way it showcases the uselessness of the NFA itself. If these AR pistols with brace are claimed to be so especially dangerous as to be on par with NFA regulated items, yet are owned by many and have been purchased for years... doesn't that show that NFA items and their regulation is pointless?
The ATF at this point serves no useful purpose beyond government bloat. It constantly changes regulations making them difficult for our citizenry to understand, and acts at a whim to do so. It invents crime to prosecute otherwise lawful citizens. The enforcement of whatever gun regulation can be thought up, whenever the ATF wants, against whomever it wants, to push whatever agenda it wants serves no purpose to the governed.